Minor Ailment Service - Principles

Key Principles for the Provision and Operation of the Minor Ailment Service (MAS)

1. Following a national exercise into MAS operational practices, 10 key principles are now being put in place. In conjunction with the 2016 Directions which encompass the service specification, all MAS providers (i.e. the community pharmacy contractor) and registered pharmacists providing MAS are expected to adhere to these principles.

The 2016 Directions

2. The MAS (Scotland) Directions 2016 (“the 2016 Directions”) provide the legal framework for MAS and include four Schedules as follows:

Schedule 1: Services to be provided as a Minor Ailment Service

Schedule 2: Terms and Conditions for the provision of a Minor Ailment Service

Schedule 3: Payment for the Minor Ailment Service; and

Schedule 4: Minor Ailment Service - Service Specification

The 10 Key Principles

3. The following 10 Key Principles are intended to support the application of the 2016 Directions. The principles are drawn from the content of the directions and, where this is the case, must be adhered to.

Principle 1:

Compliance at all times with the Directions and Service Specification for MAS is essential.

4. All MAS providers and pharmacists providing MAS must familiarise themselves with all of the requirements of the 2016 Directions. This is fundamental to the arrangements between the Health Board and the MAS provider for the provisions of MAS.

(Schedule 4, paragraph 1.1)

5. The MAS provider has ultimate responsibility for the appropriate provision of MAS in accordance with all the requirements of the 2016 Directions. These must be complied with at all times.

6. The 2016 Directions and the four Schedules are intrinsically linked. This further emphasises the need for MAS providers and pharmacists providing MAS to familiarise themselves with all aspects of these Directions.

Patient Registration

Principle 2:

MAS providers must not offer incentives to the public or staff, set targets or undertake activity that amounts to a recruitment drive to register patients for MAS

7. A MAS provider must not offer any incentives or inducements to the public to register for MAS; offer any incentives or inducements or set targets for pharmacists or staff to recruit people to register for MAS or for any other aspects of MAS.

Principle 3:

MAS providers and pharmacist(s) must only use approved MAS Stationery and publicity materials

8. Registration must be undertaken using only MAS stationery approved by Scottish Ministers. Registration using any other form of document or stationery (e.g. materials produced locally by the MAS provider) is not permitted.

(Schedule 2, paragraphs 3(b) and 7; Schedule 4, paragraph 4.4.1)

9. In addition, they may only issue or display the publicity material and the patient information leaflet made available by Scottish Ministers in respect of MAS and the provision of MAS to promote and raise public awareness of the service. Also, if listing MAS on a services offered panel, pharmacy leaflet or website then the MAS provider must not suggest that the service is exclusive to that pharmacy

Principle 4:

MAS providers and pharmacist(s) must always obtain the patient’s or representative’s consent

10. Obtaining and documenting patient (or their representative’s) consent to register and receive the associated services is fundamental to the operation of MAS. A pharmacist carrying out a registration must therefore ensure, where applicable, that the patient records their consent by signing the approved MAS stationery.

(Schedule 2, paragraph 3(b))

11. Only under certain circumstances can someone else give consent to registration or treatment on the patient’s behalf, or sign the MAS stationary in place of the patient. These circumstances are where:

The patient is under the age of 16 in which case, the parent or guardian may sign the form.

Where the patient is the subject of a Power of Attorney or Guardianship Order which allows a named person to give consent.

The patient is housebound and a representative is attending on their behalf.

(Schedule 4, paragraph 4.3.2)

12. Good practice requires that particular care is taken when registering, or providing a MAS consultation to, a patient who is housebound and has arranged for a representative to attend the pharmacy. The MAS provider should ensure that any staff involved in registration of these patients are suitably trained and competent to undertake this process.

13. Registration, or a MAS consultation, for a housebound patient must be carried out in compliance with the directions (as described in paragraph 11 above). The detailed internal process for registration of a housebound patient should be included in a Standard Operating Procedure within the pharmacy (see also paragraph 43 of this Annex).

(Schedule 4, paragraph 4.4.2 and 4.9.2)

Housebound Patients

12. Good practice requires that particular care is taken when registering, or providing a MAS consultation to, a patient who is housebound and has arranged for a representative to attend the pharmacy. The MAS provider should ensure that any staff involved in registration of these patients are suitably trained and competent to undertake this process.

13. Registration, or a MAS consultation, for a housebound patient must be carried out in compliance with the directions (as described in paragraph 11 above). The detailed internal process for registration of a housebound patient should be included in a Standard Operating Procedure within the pharmacy (see also paragraph 43 of this Annex).

(Schedule 4, paragraph 4.4.2 and 4.9.2)

Principal 5:

MAS stationery should not be signed by MAS providers, pharmacists or support staff on behalf of the patient except in exceptional circumstances.

14. MAS stationery should not be signed by MAS providers, pharmacists or support staff on behalf of the patient except in exceptional circumstances.

(Schedule 4, paragraph 4.4.4)

15. In any exceptional cases where the patient is physically unable to sign, explicit permission must be obtained from the patient and the form should be annotated with name of the signatory (in capitals) and the reason for the proxy signature.

16. In the event where the pharmacy is experiencing IT problems, the pharmacist must complete the appropriate MAS stationery manually and obtain the patient’s or patient representative’s signature on the form. Once IT functionality is restored an electronic version should be completed and the signed manual form attached.

(Schedule 4, paragraph 4.7.2 - 3)

Patient Eligibility

Principle 6:

MAS providers and pharmacist(s) must always ascertain the patient’s eligibility for MAS

17. A patient must be eligible and wish to register for MAS before a MAS provider, pharmacist or member of pharmacy staff commences the registration process.

(Schedule 4, paragraph 4.2.1-2)

18. A MAS provider, pharmacist or member of pharmacy staff should ensure that the required check on a patient’s eligibility is made prior to beginning the registration process.

(Schedule 2, paragraph 3(a), Schedule 4 paragraph 4.3.3)

19. As well as checking eligibility at the point of registration, a check must be made at each time the service is accessed thereafter to confirm that there has been no change in circumstances and the person continues to be eligible for MAS.

(Schedule 4, paragraph 4.1.1 and paragraph 4.9.1)

20. If a patient can’t provide evidence of their eligibility then the pharmacist should use their professional judgement to determine whether it is appropriate to provide MAS.

21. Patients registering for MAS should mark their eligibility category and sign the back of the MAS stationery. The pharmacist should sign the front of the form.

(Schedule 4, paragraph 4.3)

The Electronic Recording of Registrations - eMAS

Principle 7:

MAS providers and pharmacist(s) should always record complete and accurate patient information

22. Only once a patient or patient representative has given their agreement to register for MAS, and appropriate eligibility checks have been carried out, can a MAS provider, pharmacist or member of pharmacy staff begin the registration process.

23. The following information is required to support the registration of a patient electronically using eMAS (PMR systems all support this through their eMAS programmes):

Full Name

Postcode

Date of birth

Gender

CHI Number

28. It is important that this information is complete and accurate, for example the postcode is correct and properly populated in the correct information field.

(Schedule 4, paragraph 6.7)

29. A patient’s exemption category should also be recorded and confirmed each time a consultation is carried out in order to ensure that they are still eligible for MAS.

30. A patient record must be established and retained as part of the registration process which includes as a minimum:

the patient’s name and address;

the name and address of the person who gave consent to, or applied for, the registration and their relationship to the patient who is registered, where appropriate;

the reason for the patient’s eligibility to register for MAS, i.e. their exemption status;

the services provided to the registered patient as MAS, to include:

details of the treatment provided;

a record that advice only or a referral has been provided as an alternative to treatment and the associated date;

the date on which each of the above was provided; and

with respect to treatments, the name, quantity, form and strength of any product supplied.

(Schedule 2, paragraph 3(d) and 4)

31. Pharmacists and their staff should ensure that the information printed on MAS stationery is in the correct position and that this information is readable. Forms should be reprinted prior to signing if this is not the case. Note that this is reprinting of the form and not re-registering the patient. All PMR systems have the facility to reprint forms.

Principle 8:

MAS providers and pharmacist(s) should not ‘batch’ register patients for MAS other than in exceptional circumstances

32. MAS providers should not ‘batch’ register patients for MAS. The exception to this is where there has been an IT problem meaning electronic data capture has not been possible and the forms have had to be completed manually. Where this is the case then the pharmacist must notify the ePharmacy Helpdesk before they start to enter registrations or activities by batch and provide an estimate of registrations and consultations which have been delayed.

(Schedule 4, paragraph 6.8)

33. If access to the PRS is not available, a blank MAS stationery form should be completed manually and signed by the patient. Manual registration for MAS using this method is regarded as the exception; the normal route for registration is using electronic data exchange (eMAS).

(Schedule 4, paragraph 4.7.2)

34. In cases where manual registration has been necessary, the data must be entered electronically and forms generated. The signed manual forms should be attached to the associated electronically generated forms and submitted to PSD.

(Schedule 4, paragraph 4.7.3)

35. MAS providers and pharmacist(s) requiring to complete the MAS registration form manually should first contact the ePharmacy Helpdesk (0131 275 6600) indicating the reason why and when this use is expected to start and also when electronic submission of registrations will start / resume.

Deadline for Submission of MAS Stationery used for registration

36. MAS stationery used for MAS registration must be submitted within two months of the date of registration. The electronic message will be matched to the associated form and registrations may be cancelled if no form has been submitted within two months of registration.

(Schedule 4, paragraph 6.6)

37. The blank right hand side of the MAS stationery form should be torn off and discarded prior to submission to PSD.

38. Incomplete registration forms should not be submitted to PSD.

(Schedule 4, paragraph 6.7)

Principle 9:

“Lapsed registrations” can only be reactivated if the patient uses the service

39. If a MAS registered patient has not accessed the service for 12 months, their registration will lapse and will not count towards the monthly total for that MAS provider.

(Schedule 4, paragraphs 4.6.1)

40. These “lapsed” registrations can only be reactivated if the patient accesses and uses the service at that pharmacy at a later date for a MAS consultation. MAS providers, pharmacists and members of pharmacy staff must not attempt to reactivate registrations if patients have not used MAS.

(Schedule 4, paragraphs 4.1.17 to 19)

41. All registration activity, including re-activation of a lapsed registration, must be based on direct contact with the patient or patient’s representative by either the pharmacist, or by a member of pharmacy staff under the direct supervision of the pharmacist.

(Schedule 4, paragraph 4.2.2)

42. If a patient registration has lapsed and they subsequently wish to access the service, the patient is required to confirm that they remain eligible for MAS and sign the appropriate MAS stationery form.

(Schedule 4, paragraph 4.6.3)

Principle 10:

MAS providers and pharmacist(s) must at all times operate MAS professionally and ethically and in the best interest of the patient

43. MAS providers should ensure that there is a comprehensive Standard Operating Procedure (SOP) for MAS which covers all aspects of service provision including registration, registration of housebound patients, withdrawal, consultation and treatment.

44. All providers of NHS services have a duty to use NHS resources responsibly and these should be only used in the best interest of the patient. In the case of MAS, this includes registration and treatment, covering remuneration for the provision of the service as well as reimbursement of the items dispensed and provided through the service.

45. MAS providers are obliged to provide the right environment to allow pharmacists to provide professional clinical care as they consider appropriate to the patient.

46. The supply of a medicine should be in response to a patient consultation and only when it is the most clinically appropriate intervention.

(Schedule 4, paragraph 4.9.6)

Post Payment Verification

47. As with all pharmacy payments, MAS claims will be subject to scrutiny by Practitioner Services’ Payment Verification (PV) team. Any anomalies or outliers will be investigated by PV and, where appropriate, will be referred to the relevant NHS Board, and to NHSScotland Counter Fraud Services (CFS).

48. MAS providers who submit an unsatisfactory response or fail to respond to payment verification enquiries may be considered for onward referral and/or financial recovery.

49. Where after suitable investigation an NHS Board is satisfied that a MAS provider has not provided the services in accordance with the 2016 MAS Directions it can suspend payments for MAS and recover those made in respect of any appropriate period(s).